I object to proposal RY6, the site in Cyprus Place. The thriving local business occupying the site at present is a huge asset to the local area. Not only does it employ 5 people but since the closure of Martyn Channon it provides a range of goods and services which are only available here. There is no business between Ashford and Hastings providing similar service. There can be no justification in loosing this valuable asset to provide a few houses which will be of no use to local people. I use this business regularly and when doing so I shop in other Rye businesses as a result.

Sites RY2, RY4, RY5 and RY7 entirely unsustainable given locations on flood plain (Flood Zone 3) or next to rivers likely to flood due to climate change and sea level rise. 50 cm higher river banks will not fully protect. This is reality. Some of the buildings as designed (with sacrificial ground floors) at over two storeys (3.5+) will be too high and block views of historic Rye, as Bridge Point does. RY3: I object to large mass and over-height of 43-flat accommodation. RY4 site extends beyond existing buildings' footprint into Rother flood plain and proposed housing heights of more than 2 storeys will impair views towards Rye and from it — harming the town's historic character. Heights must be limited to 2 storeys. RY9: proposed density of 130 dph is absolutely absurd for historic Rye. I support 40 dph on this site. RY6: assist tenant to find acceptable site.

Overall the housing allocation sites for Rye are too dense. There is no shockingly no consideration for infrastructure, impact on schools or added traffic. RY2: Keep this for business only. It is a poor and undesirable choice for housing. RY5: This was supposed to be a mixed use development with an arts centre and small park/outdoor theatre planned by Martello development. Why the change to only housing? It is a mistake to make this a housing only area. The impact on traffic on an already crowded Undercliff Road will be significant. RY6: Rye Hire should not be forced to move from this site. They employ local people and are a successful business that is easily accessible. Additional housing this close to the town centre is not welcome and will negatively impact on the quality of life in an ancient town.
Better to place new housing next to Valley Park.

Site RY4, The Old Freda Gardham School, currently known as Rye Creative Centre, provides workspace for over 30 creative businesses including artists, art therapists, textile designers, graphic designers, architects and a daycare centre for artists with disabilities. Alongside this, every week, over 100 members of the local and wider community, use Rye Creative Centre for creative workshops and wellbeing activities.

Rye needs new homes, but also affordable workspace.
As the plan stands Rye will lose approximately 1000m2 of creative workspace.

If a development results in the loss of existing arts workspace, boroughs can use Section 106 agreements to mandate on-site replacement, or a financial contribution to a "Cultural Land Trust" to secure space elsewhere. There has been some discussion that alternative space will be provided in Rye Harbour, but currently, there are no clear guarantees, and I would like alternative provision to become part of the Rother Local Plan

I am the owner of three townhouses at Rock Channel, Rye, East Sussex.

I therefore have a direct interest in the development strategy affecting Rye town centre and the Rock Channel area.

While I recognise the need for additional housing across the district, I am concerned that elements of the draft plan imply development densities in Rye that appear excessive when considered against the town’s environmental constraints, infrastructure capacity, and historic character.

1. Housing density in Rye town centre
Density assumptions implied by the plan appear to approach levels around 100–120 dwellings per hectare in central locations.
For context, a typical two-storey three-bedroom UK house has an internal floor area of approximately 85–90 square metres, implying a ground floor footprint of around 40–45 square metres.
At a density of 120 dwellings per hectare:
• each dwelling would theoretically occupy only around 83 square metres of land
• this figure must include roads, parking, pavements, drainage infrastructure and gardens
This leaves very limited land per dwelling once circulation space and infrastructure are accounted for.
In practice, densities at this level are typically associated with apartment buildings or tightly packed urban terraces in major cities rather than the scale and character of development traditionally associated with Rye.
For illustration, I have attached Appendix A, which shows a conceptual diagram of what a density of approximately 120 dwellings per hectare represents spatially.

2. Flood risk constraints
Large areas of Rye are subject to significant flood risk due to the town’s position at the confluence of the Rivers Rother, Brede and Tillingham.
Planning evidence indicates that parts of the Rock Channel area fall within Flood Zone 3 and may also be affected by surface water flood risk.
While flood mitigation measures can sometimes be incorporated into development, intensifying residential development in areas of known flood risk requires careful scrutiny, particularly in the context of long-term climate change projections and the resilience of critical infrastructure.

3. Ground conditions and reclaimed land
Parts of the Rock Channel area are located on historically reclaimed land. Development in these areas typically requires more complex foundation solutions and ground engineering works.
These additional construction requirements can materially affect development viability and should be properly reflected when assessing realistic housing densities and site deliverability.

4. Water and wastewater infrastructure
Residents in the wider East Sussex area are aware of ongoing concerns regarding water and wastewater infrastructure capacity.
Without clear evidence that sufficient upgrades to water supply and wastewater treatment infrastructure will be delivered, further significant residential intensification risks placing additional strain on existing systems.
Local Plan allocations should therefore be supported by clear infrastructure delivery plans.

5. Affordable housing delivery
The Local Plan appropriately emphasises the importance of affordable housing provision.
However, locations such as Rock Channel — where land values, construction complexity, flood mitigation requirements and infrastructure constraints are significant — may not represent the most effective locations for delivering meaningful affordable housing provision.
Realistic viability assumptions should therefore be carefully considered when allocating sites.

6. Heritage and conservation context
Rye is one of the most historically distinctive towns in East Sussex and includes extensive conservation areas and heritage assets that contribute significantly to its character and tourism economy.
Development at densities more typical of major urban centres risks creating building forms and townscape patterns that are inconsistent with the established scale and historic morphology of the town.
Careful attention should therefore be given to ensuring that development densities and building typologies remain compatible with Rye’s historic character, conservation setting and landscape context.

Conclusion
In light of these considerations, I respectfully encourage the Council to:
• carefully review density assumptions for Rye town centre
• ensure flood risk constraints are fully reflected in site allocations
• recognise the engineering and viability implications of reclaimed land sites
• ensure infrastructure capacity, particularly water and wastewater, is clearly addressed before allocating higher density development
• ensure development densities remain compatible with the historic character of Rye
Rye is an exceptional historic town whose character and environmental context require careful and proportionate planning decisions.

Thank you for the opportunity to comment on the emerging Local Plan.

Please see attached: East Sussex County Council Representations on the Rother Local Plan ‘Development Strategy and Site Allocations Draft (Regulation 18) Version’ consultation

I welcome additional housing in this area and ask the Planning Policy Team to consider my points and concerns:
1. Reclaimed land and ground conditions
Phase One Bridge Point houses required deeply bored foundations (c12m) to satisfy Planning Consents. This is expensive and I wonder how this will deliver affordable housing.
RY2 is in a Flood Zone and ground floor living accommodation will not be permitted, building upwards will add further cost.
Since reclaimed land tends to be soft, rapid urbanization with high-density building can lead to subsidence.
Flood Risk Constraints
RY2 is adjacent to the tidal Tillingham River. As well as river flooding there is a potential risk from surface water. Significant building density, with roads, pavements etc. reduces natural floodplain storage. This will require careful scrutiny and new resilient infrastructure.
Water & Wastewater infrastructure
This is an ongoing issue in E Sussex and areas of Kent where recently a new housing estate was halted because of insufficient water supply; recently Southern Water had problems with waste back up in older properties in Rock Channel. The existing infrastructure is old and insufficient.
Affordable housing
Considering the points above, construction in RY2 appears to be potentially expensive. At the same time Rye needs affordable housing with many young people having to move away or being ‘stuck’ outside the town with nothing to do. The area does not need more holiday accommodation.
Heritage & Conservation
Rye’s local industry is tourism and visitors come to enjoy the (so far) carefully preserved character of the town. If this is diluted by too much/unattractive development close to the citadel Rye will lose visitors and business.
Housing density
The housing density seems high - I would ask the Policy Planning Team to confirm the national norm and what’s proposed here. Not just house sizes, parking as well since it’s in short supply in the town.
There is a knock-on effect with health services (GP, Dental etc) and to consider a new purpose-built centre accommodation.

Please see attached representations on questions: 2, 6, 7, 9, 13 & 49.

NETWORK RAIL RESPONSE TO ROTHER LOCAL PLAN 2025 – 2042 – DEVELOPMENT STRATEGY AND
SITE ALLOCATIONS

These representations are submitted to Rother District Council (‘the Council’) by Network Rail
Infrastructure Limited (‘Network Rail’), in respect of the Regulation 18 consultation on the
Development Strategy and Site Allocations (‘the Strategy’).

It is important that opportunities to promote the use of the railway as a more sustainable modes of
transport are identified and taken forward. The railway network is a vital element of the country’s
economy and a key component in the drive to deliver the Government’s sustainable agenda. Rother
benefits from several railway stations benefiting current and future residents, employees and others.
These stations are also likely to need investment to ensure they remain fit to service future growth
and we would encourage the Council to work with the railway to secure this investment where it is
needed.

NR is the statutory undertaker for maintaining and operating railway infrastructure of England,
Scotland, and Wales. As statutory undertaker, NR is under license from the Department for Transport
(DfT) and Transport Scotland (TS) and regulated by the Office of Rail and Road (ORR) to maintain and
enhance the operational railway and its assets, ensuring the provision of a safe operational railway.
As a matter of course, proponents of sites which are close to the railway boundary or sites which
could affect the railway asset directly are required to engage with our Asset Protection and
Optimisation team (ASPRO).

On the path towards Great British Railways (GBR), Network Rail (NR) and Southeastern Railway have
formed the South Eastern Railway (SER) which operates services through in Rother. Further services
are also operated by Southern Railway In producing these representations, NR has consulted with SER
and Southern Railway and this should be considered a joint railway response.

Representations

This section sets out the areas for which comments have been made in relation to the Regulation 18
consultation.

Vision, Overall Priorities and Strategic Objectives

NR supports the proposed changes to the Strategic Spatial Objectives (SSO). In relation to the newly
added point 11 within the SSO, NR would encourage specific reference to the Government’s proposals
to provide a presumption in favour of development round railway stations, subject to other
considerations. This provides the opportunity for densities to be maximised, an increase in the use of
stations and investment into improving the rail network to cater for the new users. NR suggests the
following amendment (in italics):

Deliver sustainable development by making the optimal use of land, especially around railway stations,
including by prioritising the use of brownfield land and ensuring all new development is designed and
built to appropriate densities, having regard to local context and character.

Infrastructure needs

NR has reviewed the most recently published Infrastructure Delivery Plan (IDP) in January 2026 to
support the Strategy. One aspect missing is the opportunity for a new station entrance at Bexhill
railway station. This will allow for improved passenger flows and extra capacity within the entrance
hall at the station, benefitting current and future users of the station.

Battle station has received central government funding to progress the proposed access for all (AFA)
scheme, to provide step free access between both platforms, to detailed design. Further funding will
be required to deliver the full works at the station. NR will provide further updates for the Regulation
19 consultation if any additional work or needs are identified.

Further, NR supports the Council’s intent to secure the timely delivery of infrastructure and we would
encourage the Council to refer to the use of planning conditions and obligations to ensure this
infrastructure is secured in a timely manner.

Preparing the Development Strategy

NR supports the changes proposed in figure 9 which seeks to deliver higher density development
around Bexhill, Battle and Rye stations. As previously noted, opportunities exist to provide additional
capacity and improved accessibility at Bexhill station and there are proposals to deliver an AfA
scheme at Battle station. Rye station has some step free access to platorms however it should be
noted that there is a level crossing at Ferry Road to the west of the station. To safely deliver higher
densities around Rye, a solution to the level crossing safety issues is needed. NR will work with the
Council to identify suitable options to deal with this matter.

Vision for Bexhill

NR welcomes the inclusion within the vision of reference to improving station capacity. This reflects
NR’s earlier comments. Increasing density in Bexhill given its connections would be considered to a
sustainable development strategy. Where possible, sites close to Bexhill station should be maximised
to enable future occupiers to benefit from the proximity to the station.

Vision for Battle and Surrounding Settlements

Battle station is proposed to benefit from AFA which will deliver step free access between both
platforms. Given this scheme will enable those with mobility issues and other means of being
encumbered to sue the station should open opportunities for better connections with existing and
future housing sites. We would welcome the Council’s consideration on how the AfA scheme at
battle station could support this. Reference should be made to supporting proposed improvements
at Battle station within the Vision.

Vision for Rye and the Eastern Settlements Cluster

NR notes the vision and proposals to increase growth in Rye. As previously noted, Rye station has
some step free access which could be further improved and consideration needs to be given to the
impact on the level crossing at Ferry Road.

Site allocations

Policy BX4 – Beeching Road Enhancement Area

NR believe the proposed site allocation should make a reasonable contribution towards improvements
at the station. This should be in terms of accessibility and supporting active travel through providing
sufficient cycle storage capacity at the station. This aligns with the proposed active travel
improvements within the draft Policy and ensures a connected link from site to station.

Policy BX5 – Land south-east of Beeching Road
NR supports the draft allocation and proposed financial contributions towards public transport as
within part v. This should specify the railway station as there are improvements that could be made.
Given its proximity to the station, the draft allocation should consider increasing the density to meet
the Government’s agenda of increasing development around railway stations.

Policy BX7 – Sainsbury’s, 1 Buckhurst Place

NR supports the draft site allocation at part v which includes providing improved public transport
infrastructure. The proximity to the railway means that a comprehensive masterplan should
consider how to improve access to the station. Given its proximity to the station, development here
should be maximised.

Policy BX9 – Land south of Terminus Road

NR notes the proximity of the railway to the south of the draft allocation. Suitable boundary fencing
and noise mitigation measures will be required to protect future occupiers. Additionally, some land
to the eastern boundary of the draft allocation is owned by the railway. It appears this land falls
within the red line of the draft site allocation. NR would be willing to discuss if this land is necessary
and how this could support the delivery of the allocation.

Policy BX10 – 30 Dorset Road

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required. The red line of the draft allocation appears to be close to, and
incorporating, NR land. NR would be willing to discuss if this land is necessary and how this could
support the delivery of the allocation.

Policy BX12 – 2a Sackville Road

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required. There are current issues of a collapsing wall impacting on the railway at
the site. Engagement with NR from early in the process is essential.

Policy BX16 - Land west of Pages Lane, Bexhill

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required.

Policy BX19 - Gorses Car Park and open space, The Gorses

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required.

Policy BX23 - Land north of Rosewood Park

The draft site allocation should explore opportunities to provide contribution towards improving
connectivity with the railway. The nearest station is Cooden however there is limited accessibility to
the station with no obvious prospect for bus services to drop off/pick up close to the station. There
is the potential for many occupiers to travel to Bexhill station which could put pressure on the
existing car park at the station. Consideration is needed to determine how this need could be met.

Policy BX27 – Beeches Farm and land north of Barnhorn Road

The draft site allocation should explore opportunities to provide contribution towards improving
connectivity with the railway. The nearest station is Cooden however there is limited accessibility to
the station with no obvious prospect for bus services to drop off/pick up close to the station. There
is the potential for many occupiers to travel to Bexhill station which could put pressure on the
existing car park at the station. Consideration is needed to determine how this need could be met.

Policy BX29 - North Bexhill Growth Area – Infrastructure Policy

Consideration should be given as to how best to connect the Growth Area with the public transport
and the railway. The draft site allocations within the Growth Area should consider how they can
contribute, individually and cumulatively, to improving access to the railway.

Proposed Site Allocations for Battle and Surrounding Areas

Policy BT1 - Land south of Hastings Road, Battle

The proximity of the site to Battle railway station means a contribution should be sought to ensure
delivery of the AfA scheme at the station to support growth.

Proposed Site Allocations for Rye and the Eastern Settlements Cluster

Policy RY6 - Former Council Depot, Cyprus Place

The proximity of the site to the Ferry Road level crossing means the impact of pedestrian and car
movements need to be considered in respect of railway safety.

Policy RY9 - Former Lower School Site, off Ferry Road, Rye

The proximity of the site to the Ferry Road level crossing means the impact of pedestrian and car
movements need to be considered in respect of railway safety.

Conclusions

We welcome the Council’s approach to securing infrastructure and promoting the railway. We look
forward to continued collaboration as the Plan develops and seeking to make best use of the rail
network and the opportunities presented from this.
I trust the above is helpful and we hope our representations will be considered. We would welcome
a follow up meeting to expand on the points made.

Please see attached:
- Development Strategy and Site Allocations EA response (Part 1)
- Interim SA and IDP EA response (Part 2)
- Rother Draft Local Plan IDP Part B - EA amendments (Part2)

Part 1 - Development Strategy and Site Allocations

Consultation on the Draft Rother Local Plan 2025–2042 – Development Strategy and Site Allocations

Thank you for consulting us on the Draft Rother Local Plan 2025–2042 – Development Strategy and Site Allocations

We have provided advice and guidance
to strengthen policies and evidence to ensure the new Local plan aligns with
national, regional and local requirements.

Environment Agency Position

Our aim is to assist you prepare and implement a sound, robust, and effective plan
that is reflective of national policy and your local evidence base. We hope that this
collaborative process leads to a plan that delivers sustainable development,
contributes to a stronger economy, and safeguards the environment for future
generations.

Delivering the Local Plan will require a strong environmental evidence base and
close partnership working to ensure development protects and enhances the
environment. It is essential that growth is supported by the right environmental
infrastructure, including flood defences, quality waste management infrastructure,
blue and green infrastructure, water supply and disposal, and pollution prevention.

Further details are provided in:
• Section 1 – General recommendations
• Section 2 – Specific comments on proposed policies and sites

Environmental evidence and data to inform Local Plan policies and planning
decisions; data – including the latest Flood Zones and Groundwater
source protection Zones (SPZs) is available at Defra Data Services Platform.

Our planning advice service

As allocated or windfall sites with relevant environmental constraints or
opportunities progress towards development, we would encourage applicants to
engage with our planning advice service as early as possible.

We can provide detailed guidance on and/or review technical information for
development proposals, prior to submission of planning applications, as part of our
cost recoverable planning advice service.

Engagement with us prior to formal submission can provide applicants with greater
certainty regarding our position and can speed up our formal response to planning
applications. It should also result in better quality and more environmentally sensitive development.

We hope that you find our comments useful, and we would be pleased to meet with
you to discuss in more detail any issues or queries you may have. Should you have
any further questions, please do not hesitate to contact us.

Part 2 - Interim SA and IDP

Consultation on the Draft Rother Local Plan 2025–2042 – Interim Sustainability
Appraisal (SA) and the Infrastructure Delivery Plan (IDP) Part A and Part B (the
Schedule)
Thank you for consulting us on the Draft Rother Local Plan 2025–2042 – Interim
Sustainability Appraisal (SA) and the Infrastructure Delivery Plan (IDP) Part A and
Part B (the Schedule). We have provided advice and guidance to strengthen policies
and evidence to ensure the new Local plan aligns with national, regional and local
requirements.
Environment Agency Position
Our aim is to assist you prepare and implement a sound, robust, and effective plan
that is reflective of national policy and your local evidence base. We hope that this
collaborative process leads to a plan that delivers sustainable development,
contributes to a stronger economy, and safeguards the environment for future
generations.
Delivering the Local Plan will require a strong environmental evidence base and
close partnership working to ensure development protects and enhances the
environment. It is essential that growth is supported by the right environmental
infrastructure, including flood defences, quality waste management infrastructure,
blue and green infrastructure, water supply and disposal, and pollution prevention.
Further details are provided in:
•
Section 1 – Infrastructure Delivery Plan (IDP) comments
•
Section 2 – Interim Sustainability Appraisals (SA) comments
We also attach the following document to our response:
•
Rother Draft Local Plan IDP Part B - EA amendments
Environmental evidence and data to inform Local Plan policies and planning
decisions; data – including the latest Flood Zones and Groundwater
source protection Zones (SPZs) is available at Defra Data Services Platform.
Our planning advice service
As allocated or windfall sites with relevant environmental constraints or
opportunities progress towards development, we would encourage applicants to
engage with our planning advice service as early as possible.
We can provide detailed guidance on and/or review technical information for
development proposals, prior to submission of planning applications, as part of our cost recoverable planning advice service.
Engagement with us prior to formal submission can provide applicants with greater
certainty regarding our position and can speed up our formal response to planning
applications. It should also result in better quality and more environmentally
sensitive development.
We hope that you find our comments useful, and we would be pleased to meet with
you to discuss in more detail any issues or queries you may have. Should you have
any further questions, please do not hesitate to contact us.

Draft Rother Local Plan (Regulation 18) - National Highways' response

Thank you for your email of 26 January 2026 consulting National Highways on the draft Rother Local Plan 2025-2042 - Development Strategy and Site Allocations (the draft Plan).

We are concerned about the safety, reliability, and operational efficiency of the Strategic Road Network (SRN). In the case of Rother district, the SRN comprises the A259 and the A21.

We have read the consultation document and understand that the focus is on the proposed site allocations. We have also read the Local Development Scheme (LDS) (March 2025) which maps out the timetable for the production of the Local Plan.

We have set out below our comments.

SRN policy context - vision-led approach:
We would like to draw your attention to the Department for Transport (DfT) Circular 01/2022: Strategic road network and the delivery of sustainable development (December 2022) which represents the government's policy for the SRN.

Plan-making needs to respond to the expectations of this policy including a vision-led approach to development. The objective of vision-led development is to manage down traffic impacts by maximising opportunities for sustainable travel and by internalising movements as far as possible through layout and design. There is also a specific section in the Circular on 'Engagement with plan-making'.

The vision-led approach to development now features in the updated National Planning Policy Framework (NPPF) (December 2024) - please see section 9. The updated NPPF also includes a requirement for Local Plans to look ahead over a minimum 15-year period from adoption. It is important to highlight this at this early stage because the time horizon for the Local Plan is relevant to the evidence that needs to be prepared to inform plan-making.

A key part of the vision-led approach, where appropriate, is monitor and manage. This is an important strategy for overseeing the appropriateness and phasing of identified highway mitigation to support the delivery of large developments. This would need to be informed by an Infrastructure Delivery Plan that should be kept live by regular monitoring during the implementation of the development strategy for the Local Plan.

We are happy to work with you on the development of appropriate policies that address the vision-led approach and monitor and manage.

Rother Local Plan 2025-2042 - Development Strategy and Site Allocations Draft (Regulation 18) Version, January 2026:
The draft Local Plan sets out proposed site allocations across the district along with some area specific policies.

We understand that 'Additional technical evidence will be prepared to ensure the potential impacts (including cumulative impacts) of the level of growth planned in Rother is appropriately considered, as well as to ensure new development is suitably located and can be adequately supported by infrastructure, and is viable, in line with national policy and guidance.'

We would encourage Rother District Council (RDC) to continue to engage with us in respect of the transport modelling and assessments in order to ensure that the approach is consistent with the guidance set out in DfT Circular 01/2022.

Furthermore, we suggest that the Local Plan considers cumulative impacts of development in neighbouring authorities. This is in line with DfT Circular 01/2022 paragraph 29 and the NPPF on strategic cross-boundary matters.

Infrastructure Needs:
We note that an updated Draft Infrastructure Delivery Plan (IDP) has been prepared in support of this Regulation 18 consultation and our comments on this document are detailed within a later section of this letter.

However, it is also important to note that we understand the draft IDP will require further revisions once the updated strategic transport modelling using the countywide model is complete. As such, the infrastructure needed to support the delivery of the Local Plan cannot be fully identified until this work is complete.

Development Strategy:
We note that following the first Regulation 18 consultation, several additional options for the development strategy have been identified, these included the 'A21 Corridor Option'.

We note that this option would have the most direct implications for the SRN. This option provides for development along the A21 trunk road within an identified corridor of settlements, together with a sustainable transport corridor (including improved sustainable travel options such as bus routes, cycling and walking infrastructure).

We would highlight that any proposed changes/improvements to any part of the SRN will require consultation with and approval from us.

Furthermore, the full impact of this option is required to be assessed as part of the updated modelling, to be undertaken in compliance with the guidance set out in DfT Circular 01/2022.

We strongly advise that RDC continue to engage with us regarding the updated modelling and preparation of the associated transport evidence base documents to ensure that any potential impacts on the SRN are appropriately assessed.

Development Strategy for Rother:
It is noted that Bexhill will be the key focus for sustainable residential and commercial growth with potential to deliver circa 4,764 dwellings and 54,672 sqm. of employment.

It is evident that the proposed development strategy will place additional strain on the SRN in this area and this will need to be fully assessed through the updated modelling work being undertaken to support the draft Local Plan.

RDC must consider Circular 01/2022 paragraph 29:
"there cannot be any presumption that such infrastructure will be funded through a future RIS [Road Investment Strategy]. The company will therefore work with local authorities in their strategic policy-making functions in identifying realistic alternative funding mechanisms, to include other public funding programmes and developer contribution strategies to be secured by a policy in a local plan or spatial development strategy."

The draft Local Plan notes there are 'opportunities for sensitive development in the sub-area during the timeframe of the Local Plan, where sustainable and related to an existing settlement, including those alongside the A21. Longer term (beyond the timeframe of the new Local Plan), the delivery of significant improvements to create a sustainable transport corridor could open up opportunities for future development along the A21 corridor, which could be addressed in a plan review.'

RDC states that there is potential to deliver 996 dwellings and 4,350 sqm of employment floorspace across the Northern Rother sub-area.

Paragraph 6.85 of the draft Local Plan states:

'The A21 provides road connections between the villages north and south. In the long- term, the A21 could become a sustainable travel corridor with buses given priority, linked to walking, cycling and wheeling routes. The Transport for the South-East (TfSE) Strategic Investment Plan identifies bypasses on the A21 at Flimwell and Hurst Green as necessary transport interventions to decarbonise transport in the south-east by 2050. However, these are not currently funded and there is a lack of evidence they will come forward at any point, including during the timescale of the Local Plan.'

Introducing a sustainable travel corridor along the A21 aligns with DfT Circular 01/2022 policy by encouraging walking, wheeling, cycling and public transport use as the natural first choice. However, we would again reiterate that the need for any SRN mitigation must be considered after all options have been assessed to maximise the accessibility by sustainable transport modes. There cannot be any presumption that SRN-related infrastructure to mitigate Local Plan impacts will be funded through a future government's Road Investment Strategy (RIS). Funding and delivery of necessary SRN infrastructure to support planned growth is a matter for the Local Planning Authority (LPA) to lead on through the Local Plan process.

Furthermore, it is also important to note that while RIS3 has yet to be published, the interim statement (2025/2026) highlights that RIS3 will be focused on maintenance and renewal (para.4.3):

'While RIS3 has yet to be agreed, it is likely that investment will be increasingly focussed on maintaining and renewing the existing Strategic Road Network, including replacing and renewing major bridges, viaducts and other structures.'

Site Allocations:
We note that there are circa 162 site allocation policies (some are area specific and can also encompass more than one site).

Our review has sought to identify immediately apparent site-specific matters of interest to us, which are:
- Sites which would require a new access onto the SRN (this includes sites that do not abut the SRN but would require a new access onto the SRN as part of their wider transport strategy)
- Sites which propose to use an existing SRN access Sites which abut the SRN but would take access onto the Local Road Network
- Sites located near the SRN.

Sites requiring a new access onto SRN All sites seeking a new access onto the SRN must demonstrate evidence of: Policy compliance regarding new accesses on the SRN as per DfT Circular 01/2022, in particular paragraphs 18 to 25 Design Manual for Roads and Bridges (DMRB) compliance and Stage 1 Road Safety Audit (RSA), Walking, Cycling and Horse-riding Assessment and Review (WCHAR) etc.

In relation to policy compliance, we would highlight paragraph 19 of the Circular (our emphasis):

"19. On this basis the principle of creating new connections on the SRN should be identified at the plan-making stage in circumstances where an assessment of the potential impacts on the SRN can be considered alongside whether such new infrastructure is essential for the delivery of strategic growth. Moreover, the company will need to be satisfied that all reasonable options to deliver modal shift, promote walking, wheeling and cycling, public transport and shared travel to assist in reducing car dependency, and locate development in areas of high accessibility by sustainable transport modes (or areas that can be made more accessible) have been exhausted before considering options for new connections to the SRN. There may also be limited opportunity for new connections to be considered as part of public funding programmes to support new development, although necessary infrastructure in up- to-date plans and strategies should be favoured in such instances."

We would therefore expect an appropriate assessment to be undertaken and included - either within the Local Plan transport evidence or as part of the explanation of the development strategy - demonstrating how this has been addressed through plan-making by RDC. It may be the case that it can be drawn from other existing sources that form part of the Local Plan evidence base.

It is important that RDC demonstrates that they have followed this process as any new connections on the SRN can create additional risk to safety and reduce the reliability and efficiency of journeys.

In respect of these sites, it is also strongly advised that individual site-specific advice be sought from us as soon as possible.

Sites proposing to utilise an existing SRN access:
All sites which propose to utilise an existing SRN access will need to fully assess any impacts arising from the proposed development traffic.

It is important to note that we would not support the intensification of use of an existing SRN access where there would be a detrimental impact on safety.

Any proposed upgrade/improvement of an existing SRN access would need to be fully assessed in line with the relevant guidance set out in DfT Circular 01/2022 and DMRB.

For all sites where SRN access is critical to the deliverability of the development, the required assessments should be undertaken as soon as possible, in advance of the Regulation 19 submission.

Sites which abut the SRN:
All sites which abut the SRN will need to consider any boundary issues, eg drainage, lighting, geotechnical, boundary treatments, in consultation with us.

Sites near the SRN:
For sites located near to the SRN, it will be particularly important that they are supported by an appropriate Transport Assessment at the planning application stage and are advised to seek early engagement with us at the pre-application stage. However, this does not preclude the need for Transport Assessments for sites which are located further away which are of a development quantum which could have a material traffic impact on the SRN.

We note that the cumulative traffic impact of all proposed site allocations is to be assessed as part of the updated modelling based on the East Sussex Countywide model.

Evidence-base: Strategic transport modelling It is important that plan-making is informed by proportionate up-to-date evidence.

In respect of transport, we expect the beginning stages of plan-making to be supported by baseline evidence for the highway networks across Rother District, with our focus being on the SRN. We note that the transport evidence which has been published as part of the
current consultation dates from 2023 and therefore is not able to specifically consider the impacts of the specific sites identified in the main Regulation 18 consultation document.

We understand that the intention is to utilise the East Sussex Countywide Transport Model (ESCWTM/ 'countywide model') in advance of subsequent consultation stages to 'underpin and develop a detailed Shared Transport Evidence Base'.

This needs to set out current and future baseline (end of plan period + extant permissions) information on the performance of junctions across the highway networks. We understand that this will be informed by updated transport modelling using the Countywide strategic model.

Baseline information on the current and expected performance of junctions across the highway networks (without the emerging Local Plan) is relevant to the site selection process and needs to be produced in advance of the detailed Regulation 19 Local Plan to inform its preparation.

We are happy to be engaged with the scoping, calibration, and validation of this work, along with colleagues at East Sussex County Council who are responsible for the Local Road Network (LRN).

Once established, the strategic transport model can then be used to test development strategy options being considered by the council for the Local Plan.

Evidence base: Infrastructure Delivery Plan (IDP) January 2026. The IDP is a useful piece of evidence to identify what, where and when in terms of the infrastructure needed to support the development strategy in the Local Plan. It can identify schemes, estimated costs, and when the mitigation will be phased alongside the build-out of the development strategy.

We have reviewed the IDP Part A and Part B (The Schedule) and would note the following points:

Strategic Corridor Improvements The A21 and A259 corridors have been identified as requiring capacity management and selective enhancements to accommodate forecast growth. The IDP confirms that any improvements along this corridor should be aligned with National Highways' RIS3 (2026 - 2031), and the LTP4 Investment Plan priorities. We would note that RIS3 is yet to be published, however, the outlined approach would be acceptable in principle. It is important to appreciate that the focus of RIS3 will be on maintenance and renewal; there is uncertainty about the future of RIS3 pipeline projects identified in RIS2. The current position on the A21 Safety Package scheme is available from our website: https://nationalhighways.co.uk/our-roads/south-east/a21-safety-package/

Integration with multi-modal travel: We welcome the statement in Paragraph 3.40 of the IDP which outlines that road interventions must support sustainable travel choices, with new and upgraded infrastructure planning alongside priority measures, cycle lanes, and pedestrian infrastructure. Such improvements should be designed in accordance with appropriate DMRB standards with any proposals submitted to us for approval.

Phased delivery and prioritisation: We agree that road network improvements should be phased in line with housing and employment delivery to ensure new capacity and infrastructure is in place at the right time as development comes forward.

Financial & delivery requirements: It should be noted that any improvement schemes on the SRN would be expected to be delivered via a s.278 (Highways Act 1980) agreement between the developer and National Highways. We do not accept developer contributions, with priorities for the SRN set in the government's RIS.

It is also important to note that RIS3 has yet to be published and as such there should be no reliance on any schemes that may be included within it. As highlighted above, there is uncertainty about RIS3 pipeline projects identified in RIS2.

We would also highlight paragraph 29 of DfT Circular 01/2022 (our emphasis):

'New connections and capacity enhancements to the SRN which are necessary to deliver strategic growth should be identified as part of the plan-making process, as this provides the best opportunity to consider the cumulative impacts of development (including planned growth in adjoining authorities) and to identify appropriate mechanisms for the delivery of strategic highway infrastructure. However, there cannot be any presumption that such infrastructure will be funded through a future RIS. The company will therefore work with local authorities in their strategic policy- making functions in identifying realistic alternative funding mechanisms, to include other public funding programmes and developer contribution strategies to be secured by a policy in a local plan or spatial development strategy.'

We welcome the reference to the 'vision and validate' approach (also known as 'monitor and manage') in Paragraph 10.9 of the IDP.

We consider that it could be beneficial to discuss the suitability of a 'Monitor and Manage' approach for individual proposed developments on a case-by-case basis at the appropriate time during the planning process, as part of a collaborative approach involving us, the LPA, developers and ESCC.

The IDP Part B (the Schedule) lists a number of schemes which directly impact the SRN.

We note that we have been identified as a 'Delivery Partner' for some of these schemes. As previously noted, Paragraph 10.21 of the IDP states that a 'Delivery Partner' is defined as: 'any strategic stakeholder (public or private) involved in the planning, design, technical approval, or funding of infrastructure; they are not necessarily the body that directly delivers the infrastructure itself.'

Based on RDC's definition, we would be a 'Delivery Partner' for all schemes on the SRN as technical approval from us would be required. Any proposed changes to the layout or operation of the SRN will need to be approved by us, with the changes designed in accordance with appropriate DMRB standards and assessed in compliance with DfT Circular 01/2022.

For the avoidance of doubt, unless otherwise specified by us, any identified SRN schemes necessary to support planned growth will not be funded or delivered by National Highways.

With regard to the Schedule itself, it would be useful to have additional information presented in relation to the presented schemes, where applicable, particularly for those classified as critical or essential:

Scheme drawing number reference LPA planning application reference(s) if scheme is linked/conditioned to development(s) Any identified trigger points (development thresholds) at which scheme is required.

We have not undertaken a detailed review of all SRN schemes included within the Schedule as we understand that the transport modelling evidence for the draft Local Plan, based on the latest site allocations, may result in changes to infrastructure requirements. As such, we anticipate that there will need to be a further update to the IDP once the modelling is completed. We have no further comments at this stage.

National Highways will need to participate in discussions involving East Sussex County Council (ESCC) and RDC, to ensure that the agreed modelling scope, specifications, and assumptions are appropriate and proportionate to the needs of the emerging Local Plan.

The IDP is a useful piece of evidence for documenting the outputs from the monitor and manage strategy which needs to form part of the implementation of the Plan. It would benefit from a chart plotting the phasing of essential transport infrastructure alongside the build-out of the development strategy to ensure identified mitigation is delivered at the right time in the development cycle. We are happy to be engaged with the development of further updates to the IDP and the monitor and manage strategy.

Expectation management: We must be clear that the funding and delivery of mitigation to the SRN that is necessary to support the development strategy in the Local Plan are matters for the LPA to decide and manage through the Local Plan process, including during its implementation.

Priorities for investment in the SRN are set in the government's Road Investment Strategy (RIS). There cannot be a presumption that improvements to the SRN necessary to support planned growth in the Local Plan will be funded and supported through a future RIS. RIS3 (2026-2031) will be focused on maintenance and renewal.

We are happy to be engaged in the process of assessing proposed mitigation, e.g. safety and design standards, but will not be responsible for funding or delivery.

Keep informed: We hope these comments are clear and helpful. We are happy to work with Rother District Council on an on-going basis as the Local Plan, including the evidence base, progresses.

Please keep us informed about the development of transport related evidence and the next stage of the Draft Rother Local Plan.

We would also like to share with you our 'Planning for the future - A guide to working with National Highways on planning matters' (October 2023), which is available from our website. This planning guide describes the approach we take to engaging with the planning system and the issues we look at when considering draft planning documents such as Local Plans.

We have also prepared a short explainer video outlining how we engage with planning. This video is available from our website under the heading 'Our support for plan-making and decision-taking': https://nationalhighways.co.uk/our-roads/planning-and-the-strategic-road- network-in-england/. In addition, we have prepared a Local Plan brochure outlining how we engage with plan-making which is available from the same section of our website.

Should you or any others have any queries regarding our response, please contact us.